Colleagues,

In my role as president of an employee health software company, I am rooutinely asked to sign Business Associate Agreements (HIPAA confidentiality agreements) with the hospitals using our software -- since in the course of converting their legacy databases and providing ongoing support, we routinely view medical information pertaining to employees, volunteers, contractors, students and licensed independent professionals.

Today I was intrigued that an individual with the title General Counsel for Health Sciences informed me that their medical center does not consider the personal medical information contained in their employee health database to be protected by HIPAA. I'd be interested in knowing how prevalent this position is. Has anyone else been given that information by their hospital's legal department? If you're not comfortable revealing the name of the institution, please feel free to reply to me individually rather than to the entire list.

Respectfully,

Joe Fanucchi

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Joe Fanucchi MD FACOEM
President and Medical Director
MediTrax / OHS, Inc.
o:925-820-7758
c:925-368-3367